Sweetwater, a Delaware limited liability company, was formed in April 2018 and became a
registered investment adviser with the SEC on December 4, 2019. As indicated on the Firm’s
Form ADV Part 1A, James Gamett, Gregg Parise, and Brent Granado are the Firm’s ultimate
beneficial owners. Sweetwater Secondaries Fund II GP LLC and Sweetwater Private Equity III
GP LLC serve as the general partners of the Firm’s clients.
The Firm is an investment management firm that provides advisory services on a discretionary
basis to a number of privately offered pooled investment vehicles (collectively, the “Funds” and
each a “Fund” and an “Advisory Client”). In the future, Sweetwater may provide discretionary
portfolio management services for other types of pooled investment vehicles, special purpose
vehicles or separately managed accounts. The Firm also provides advisory services on a non-
discretionary basis to a separately managed account (“SMA”).
Sweetwater Secondaries Fund II GP LLC and Sweetwater Private Equity III GP LLC (each an
“Affiliated General Partner”) serve as the general partners of their respective Advisory Clients.
The Affiliated General Partners are related persons of Sweetwater and are under common control
with Sweetwater. While the Affiliated General Partners retain management authority over the
business and affairs, including investment decisions, of their respective Advisory Clients,
Sweetwater has been delegated the role of investment adviser.
Sweetwater intends to offer co-investment opportunities to Fund investors interested in
participating in any such opportunity. Decisions regarding whether and to whom to offer co-
investment
opportunities, as well as the applicable terms, are made in the sole discretion of
Sweetwater or its related persons or other participants in the applicable transactions. As such, co-
investment opportunities may be offered to some and not other Fund investors, in the sole
discretion of Sweetwater or its related persons, and certain persons other than Fund investors, will,
from time to time, be offered co-investment opportunities, in the sole discretion of Sweetwater or
its related persons. When and to the extent that employees and related persons of Sweetwater and
its affiliates make capital investments in or alongside certain Funds, Sweetwater and its affiliates
are subject to conflicting interests in connection with these investments. See Item 8.B. below. The
Affiliated General Partners or their affiliates may charge fees or carried interest with regard to the
portion, if any, of any investment opportunity which the Affiliated General Partners so allocate to
a co-investment vehicle.
Sweetwater’s investment management and advisory services to Advisory Clients are provided
pursuant to the terms of the applicable private placement memorandum, offering documents or
governing documents, which set forth investment strategies and limitations. Advisory Clients’
beneficial owners cannot obtain services tailored to their individual specific needs nor will any
beneficial owner of a Fund be able to impose restrictions on the types of investments held by such
Fund.
Sweetwater does not participate in a wrap fee program.
As of December 31, 2023, Sweetwater managed $1,100,398,679 in regulatory assets under
management on a discretionary basis and $39,518,068 on a non-discretionary basis.